Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
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